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I learnt the concept of FBO/ Omnibus account/ Pooled account, so considering our models, how can we charge our service fee (let’s say 2% of the transaction amount) on behalf of our merchants (since we cannot touch the fund)?

You can charge whatever commission you want. That commission is YOURS, not your clients or the payers. Those funds belong to you. Your commission can be as low as zero (0), or 50% or 100%, you can charge whatever you want. 

Please note, you would still need a mini-compliance. For template-based mini compliance, we charge €12,500 (one-time) for it. This would also include answering the AML Questionnaire as provided by the EMI for qualification.

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This page was last updated on January 16, 2023.